|April 2009 Newsletter
Have you checked your training records lately?
Check your current training records - if you are close to the expiration date make your reservations now for any of our classes throughout the year. We always remind attendees a few days prior to the class.
Air importers are experiencing numerous problems with foreign shippers into the U.S. Judging by our workload it would appear that most of the overseas manufacturers simply did not get the 2009 Edition of the IATA Regulations as well as the updates from IATA or train their employees.
You can download the 2009 Addenda directly from IATA at http://www.iata.org/whatwedo/cargo/dangerous_goods/
IATA has provided three updates plus a Lithium Battery Guidance Document which is a very valuable tool.
Brokers, forwarders and distribution agencies seem reluctant or simply forget to request a current MSDS from the manufacturers. Without a current MSDS you will have a difficult time complying with the regulations. We remind everyone again that Special Provision A45 has been discontinued and the terminology “Not Restricted” no longer applies to Lithium Batteries. Lithium Metal Batteries are forbidden on passenger carrying aircraft on shipments into, out of, or transiting the United States.
There are now six entries and six individual packing instructions dealing with Lithium Batteries as well as five Special Provisions. If you are a novice in handling lithium batteries you should also check out Appendix A in the IATA Regulations. Suggestion: Don’t visually scan these items quickly – read them carefully….very carefully.
On March 30 IATA issued another addendum updating USG-02 which clarifies the issue of lithium metal batteries as well as other corrections covering other sections of the IATA Regulations.
Not counting this newsletter, since 2001 we have drawn attention to lithium batteries and many rule changes in 27 newsletters.
Feedback from airlines…..
Airline employees compare notes with us on an almost daily basis. Some of the items that have caused rejections so far this year include failure to use the new excepted quantities label and the new non-regulated lithium battery label that must have a phone number with international access codes for information about the shipment.
Also, the air waybill information about the lithium batteries required by IATA Part 1 of P/I’s 965, 966, 967, 968, 969 and 970 is rarely followed. Since most air carriers have one employee checking the freight while another employee checks the documentation the requirement to properly identify the cargo is not always met.
“Not Restricted” and “Not Regulated” does not always mean “Not Hazardous”. Excepted quantity is a good example. The very restricted number of chemicals that are permitted and the inner and outer packaging limitations plus the triple method of testing and packing reduce the possibility of a major incident substantially. But, that doesn’t mean the chemical magically becomes non-hazardous. We get numerous e-mails from shippers telling us their product is not hazardous because of the small quantity. Not so. Some of the requirements may have been “excepted” but it remains dangerous. That’s why they call it “excepted quantity”.
Non Vessel Operators (NVO)
Despite IMO’s clarification and interpretations from Regulatory personnel NVOs continue to refuse shipments unless the shipper provides quantities of inner packagings for combination packagings. And now they refuse lithium battery shipments for the same reason. It seems odd that commerce must stand still for companies that demand unnecessary and often confusing information based upon erroneous information. When we ask to cite the regulation the NVO personnel are stumped usually because they do not possess a copy of the IMDG Code in the office or on their computer. The regulations and Special Provisions require very strict compliance by the shippers and if the dangerous goods declaration is completed correctly and the packaging is correct and properly marked and labelled there is no valid reason for rejection. Making up their own rules that usually end up violating documentation requirements, causes unnecessary delays, extra costs and a lot of frustration. Even more important, it defeats the purpose of the documentation, which is to provide basic information for the vessel’s crew and emergency responders.
The only reference to inner packagings quantities is in 22.214.171.124.8 referring to aerosols and the requirement to note on the documentation when the capacity of the aerosol container is above 1000 ml.
Why do NVOs frustrate their clients? It kind of reminds me of when I was a young lad and when my mother told me do something and I would ask “Why?”….her answer was usually “Because!”
EHS (Environmentally Hazardous Substances)
ICAO issued guidance on how to label shipments that were only EHS UN 3077 and UN 3082 – no other hazard involved. This would be particularly helpful for EHS shipments moving by surface within the European Union.
For dangerous goods that meet the definition of hazard classes 1 through 8 that are also Environmentally Hazardous Substances the labeling should appear like this example:
Reminder – check your MSDS’ Transportation Section to determine when this would apply. Newer versions address this topic.
For ocean shipments the old Marine Pollutant
has been replaced by the new Marine Pollutant (EHS) label.
Dangerous Goods Advisory Council
For over thirty years the DGAC has been a leader in promoting safety in transportation. The council has been an advocate for the chemical industry and transporters of dangerous goods/hazardous materials. Your company should seriously consider becoming a member of this outstanding organization.
Mark your calendar:
Our Soap Box
We rant and rave and preach about safety in transportation most of the time. The next time you are tempted to sneak undeclared dangerous goods past a carrier stop and ask yourself would you do so if you were also going to be a passenger on that same aircraft, train, or bus?